By: Dr. Anna Scott, Chief Science Officer & Co-Founder, Project Canary
Today, the EPA announced upcoming rule changes to their federal methane oil and gas rules. The proposal modifies the existing rules (OOOOa) and proposes two new rules (OOOOb, OOOOc) that enhance monitoring for new and existing oil and gas facilities. These rules, if enacted, would bring many of the latest industry best practices that we are committed to, support, and enable on our customer’s well pads and transport systems every day to the rest of the nation. “While efforts to cut carbon dioxide emissions require systemic change, such as retooling the way society generates and uses energy, methane is easier to target,” (Axios Generate, Nov 2, 2021) and incredibly potent.
“Acting rapidly to deploy readily available methane mitigation measures by sector can immediately slow global warming.” Environmental Research Letters 16, no. 5 (2021): 054042.
At Project Canary, we consistently advocate for the highest air, water, land, and community standards across the energy supply chain. That’s why we were pleased to see these new rules out for comment and consideration. We join industry leaders like Cheniere, BP, Equinor, and many more in applauding the leadership role our EPA is taking to strengthen federal methane regulations.
From my first read through all 600 pages, here are some things that stood out:
- Coverage of both new and existing facilities
- Colorado-style quarterly monitoring frequency, with allowance to reduce frequency if low emissions can be proven
- Allowance for new technology and, for the first time, the standard is based on leak rate. This is big. Previous rules stymied new tech adoption, and standards were based on LDAR for concentration, not leak rates.
- Focus on emissions reduction from previously unregulated sources, such as phasing out pneumatic controllers, focusing on operational events like liquids unloading, and eliminating flaring
- Big impact: ~4 million tons of CH4 to be reduced from 2022 through 2035.
- “…mitigation measures, such as leak detection and repair programs, along with the fulfillment of company commitments of capped leakage rates, could avoid around 0.1 °C of global-mean warming by midcentury and 0.2 °C by the end of century relative to a no further action baseline that suggests the oil and gas sector could contribute 0.15 °C to warming by 2050 and 0.25 °C by 2100 (figure 4).” Environmental Research Letters
- Methane is now a common part of the volatile emissions discussions, including the Methane Pledge released today.
- Leaders of more than 90 countries will sign the U.S. and E.U.-sponsored Global Methane Pledge, designed to cut emissions of the potent but short-lived planet-warming gas methane.
Here’s where I think the EPA didn’t go as far as it should have gone:
- Flaring: no bold commitments here. In my view, the industry is out ahead of the EPA here in calling for reductions. See, e.g.
- Single wellhead sites don’t need coverage: in our view, small, intermittent, but persistent leaks matter too. Just because these leaks fall below the 10kg/hour threshold doesn’t mean they don’t add up. Every molecule counts in this battle.
- No deep consideration of continuous monitoring, which is now deployable in every North American basin with high fidelity data (not a total surprise though, based on conversations earlier this year.)
PS: I am proud that Will, Chris, and I co-founded Project Canary aligning the business model and being on the right side of history. We’re a Public Benefit Corporation committed to altering the course of climate change. I know many environmental champions are working throughout the industry who would love to praise these rules publicly but can’t. If this is you, we’re hiring. Help us Give Emissions the Bird.